Guidelines & Application Procedures for API-RP-578 Positive Material Identification ( PMI) Using XRF/OES Technologies

by Don Mears

Presenter-Don Mears
President of Analytical Training Consultants, Inc. and coordinates the sales, marketing and training program for XRF/OES Technologies. This involves the analyzers operation and training in radiation safety that meets local, State, Federal and International registration requirements. This includes certified report generation for proper material verification programs with the owners/users in the petrochemical, oil and gas industry.

Mr. Mears has worked in the oil, gas and refining industry for 30 plus years. He held positions which included preparation and delivery of training presentations and has taught numerous industry courses explaining and applying API standards and recommended practices. This included involvement in two API work groups for revision of API Manual of Petroleum Measurement Standards Chapter 3-Tank Gauging Section 1B-"Standard Practice for Level Measurement of Liquid Hydrocarbons in Stationary Tanks by Automatic Tank Gauging" and API 2350 Overfill Protection for Storage Tank in Petroleum Facilities.
Mr. Mears is the Author of the API RP 578 PMI Certification Course and is a certified API Training Provider.

Setting the Tone

Why a Certified API RP-578 PMI Training Course should be given ?
OSHAs Programs of-Regulation & Enforcement
Process Safety Management-(PSM)-1910-119 National Emphasis Program-(NEP)-CPL 03-00-004

Chemical Safety Board-BP Texas City Refinery Fire

API Standards: 570,510, &653- Mechanical

Integrity

All the Reported & Unreported Near Misses the Oil & Gas Industry has experienced, but because of:
Luck Proper PMI, Inspection Training (RAGAGEP ) / API RP 578

Regulations and Enforcements

Process Safety Management-(PSM)-1910-119-Highly Hazardous Chemicals-(HHC)-February 24, 1992 Regulation National Emphasis Program-(NEP)-CPL 03-00-004June 7, 2007 Enforcement
Understand & Apply API Recommended Practice 578 Positive Material Identification (PMI) Guidelines- September 17, 2007 2nd Edition Approved Applying Recognized and Generally Accepted Good Engineering Practices(RAGAGEP) for Inspection of Material, Both in the Warehouse & Field Through Positive Material Identification (PMI) Using XRF/OES Analysis

Understand OSHAs Definition for Process Safety Management PSM

To understand PSM and its requirements, both employers and employees need to understand how OSHA uses the term Process in PSM.

Process means any activity involving a highly hazardous chemical including using, storing, manufacturing, handling, or moving such chemicals at the site, or any combination of these activities.

For purposes of this definition, any group of vessels that are interconnected, and separate vessels located in a way that could involve a highly hazardous chemical in a potential release, are considered a single process.

OSHA Requires Information on the Equipment in the Process

Materials of construction, ( PMI ) Piping and instrument diagrams (P&IDs), Electrical classification, Relief system design and design basis, Ventilation system design, Design codes and standards employed, Material and energy balances for processes built after May 26, 1992, and Safety systems (e.g., interlocks, detection, or suppression systems). Employer shall document Equipment complies with:

RAGAGEP

Inspection Scheduling by OSHA-NEP All Refineries Covered in the next 2 years 40% in the First year 60% in the Second Year All 143 USA Refineries
OSHA Has Expanded this to the Petrochemical Industry Also !!

Houston Chronicle / OSHA Interview March 10, 2008

Regulation and Enforcement found Slew of Violations

Houston Chronical -OSHA NEP-3-10-08.pdf

Why Did OSHA Establish an NEP ?

According to OSHAS Data Base;
Since May 1992 (36) Fatality/Catastrophe (FAT/CAT)

incidents related to HHC have Occurred

Incidents include 52 Employee Deaths and 250 Employee

Injuries, 98 required Hospitalization

The number of Refinery Incidents Surpasses the

Combined Total of the next 3 highest Industries over the same period Chemical Manufacturing-12 FAT/CAT Industrial Organic Chemical Manufaturing-12 FAT/CAT Explosive Manufacturing-11 FAT/CAT

NEP Reasons Why

According to OSHAS Data Base : ( Examples Used )

BP Texas City Texas, March 23,2005 had: Killed-15 people Injured-170 people Kern Oil, Bakersfield, California, January 19,2005 Killed -1 person Injured- Multiple Giant Industries Ciniza Refinery, Gallup, New Mexico, April 8,2004

Killed None
Injured-6 people Hospitalized-4

The above Reasons to Practice: RAGAGEP

OSHAS NEP PROGRAM

WHY THE URGENCY?

Safety Bulletin from U.S. Chemical Safety and Hazard

Investigation Board (CSB)BP Texas City, Texas Refinery Fire!!!!
RHUBulletin-BP Texas City.pdf

American Petroleum Institute API

Standard-API-570-Piping Inspection Code Standard-API-510-Pressure Vessel Inspection Code Standard-API-653-Storage Tank Inspection Code Recommended Practice-API-RP-578-Material Verification Program-MVP/PMI

RAGAGEP

Occupational Safety and Health Act OSHA

Process Safety Management-(PSM)-1910-119Highly Hazardous Chemicals-(HHC)

NDT Inspection Companies-Mechanical Integrity

National Emphasis Program-(NEP)-CPL 03-00004

Explanation As it Applies to PMI

Mechanical Integrity Needs in Oil & Gas Industry

Understanding HOW,WHY,& APPLYIING:

ATC API578 PMI Certification Training Course

Guidelines & Application Procedures For Positive Material Identification (PMI)

with
XRF & OES Technologies

Introduction
What is the Purpose of this Course ?
Purpose of the Course is to certify and re-certify any API 570 & 510 inspectors for PMI Inspection requirements, and any QA/QC, Reliability Inspectors, Maintenance & Warehouse personnel. Instruction for understanding and applying API RP 578 through an approved API Training Course, that will qualify personnel in proper Guideline and Application procedures utilizing XRF and OES technologies for PMI.
The course is covered in 2 day sessions and instruction on both classroom theory and field testing procedures.

Through Understanding API RP 578 Guidelines Through Application of proper PMI testing procedures
The need and now requirement for Positive Material Identification (PMI) has dramatically grown in the past few years in refinery and petrochemical plant operations to 100% alloy material verification in today's risk-based QC environment.

Why do PMI?
Explains How OSHA Instruction-CLP 03-00-004 Nation Emphasis Program (NEP) Applies to The Refining Industry

Source: Marsh and McLennen (property protection and risk consultants)

PMI Can Prevent The Largest Losses

Process Safety Management (PSM) 29CFR1910.119 With Proper Material Verification Program and Training

41% of the 170 largest losses in the hydrocarbon process industry resulted from failures of piping systems
Second International Symposium on the Mechanical Integrity of Process Piping January 1996, Houston, TX, USA

Understand & Apply API Recommended Practice 578 Positive Material Identification (PMI) Guidelines

PMI Cycle Overview

Applying Recognized and Generally Accepted Good Engineering Practices(RAGAGEP) for Inspection of Material, Through Positive Material Identification (PMI) Using XRF/OES Analysis

Asset Management & Asset Recovery

Reasons Why You Should Follow API RP 578 Recognized And Generally Accepted Good Engineering Practice (RAGAGEP) are engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve (See CCPS [Ref. 33]).

Inspection Scheduling by OSHA All Refineries

Important information is found in APPENDIX A regarding the Static List of Inspection Priority Items (IPI) and contains questions that the Compliance Safety and Health Officer (CSHO)s are to address in their compliance evaluation of an employers refinery Process Safety Management (PSM) program. It should be noted that both PMI and proper OPERATOR TRAINING programs are QUESTIONS that the (CSHO) will address to the Owner/Operator as to compliance with their Process Safety Management (PSM) program.

Inspection Scheduling by OSHA All Refineries Section E-10 Positive Material Identification (PMI)
Does the employer ensure that replacement piping is suitable for its process application?
Yes, No, N/A If no, possible violations include: The employer did not follow RAGAGEP when it failed to conduct positive material identification (PMI) testing to ensure that construction materials of replacement/repaired piping were adequate for process conditions (An example RAGAGEP for PMI testing for existing piping systems includes but is not limited to, API RP 578, Material Verification Program for New and Existing Alloy Piping Systems, Section 4.3), and CSB, Safety Bulletin Positive Material Verification: Prevent Errors During Alloy Steel Systems Maintenance, BP Texas City, TX Refinery Fire);

Inspection Scheduling by OSHA All Refineries Section K Proper Operator Training

Have operating employees been trained on the procedures they are expected to perform? If NO, Possible Violations Include: The employer did not provide initial operator training on each specific procedure operators are expected to perform; or 1) The employer did not document the training,

2) The employer did not document the means used to verify the training, or
3) The employer did not verify that the operator understand the training.

Inspection Scheduling by OSHA All Refineries Section K

Proper Operator Training

Based on the employers explanation of their management of operator refresher training (See document request in Section X.E.3.o.), have the five randomly selected operating employees received, completed, and understood the refresher training (See document request in Section X.E.3.n.)? For each employee who operates a process, has the employer ensured that the employee understands and adheres to the current operating procedures and that the refresher training is provided at least every three years-- more often if necessary?
YES, NO,N/A

Inspection Scheduling by OSHA All Refineries Section K Proper Operator Refresher Training
If no, possible violations include:
1) The employer did not provide operator refresher training at least every three years or more often, if necessary (e.g., on a frequency consistent with that determined through consultation with employees); or 2) The employer did not document the training; 3) The employer did not determine that the operator understood the training it received; or

4) The employer did not document how it verified the training

Inspection Scheduling by OSHA All Refineries

Incident Investigation Report

The CSHO must document in the INCIDENT INVESTIGATION REPORT the number of Actual and a Near-Miss incident which has occurred in you plant. A very important part of this is the Factors that contributed to the incident. In section Q of Appendix A OSHA list examples and PMI and Training are a part of this list:

Examples of "Factors that contributed to the incident/causal factors can include, but are not limited to:

Inspection Scheduling by OSHA All Refineries

Incident Investigation Report Examples of "Factors that contributed to the incident/causal factors can include, but are not limited to: The employer did not design, operate, maintain, inspect, or change (MOC) equipment or equipment systems per RAGAGEP; The employer did not train its employees in its procedure for transferring product from the Chemical X intermediate tank to Reactor 23; The 3-inch reactor transfer line was replaced without conducting a PMI, as a result, the replaced piping that was constructed of an off-specification material failed in a short period of time.

Conclusion
Reasons Why! This Course should be given !
OSHAs Programs of-Regulation & Enforcement

Process Safety Management-(PSM)-1910-119 National Emphasis Program-(NEP)-CPL 03-00004

Chemical Safety Board-BP Texas City Refinery Fire API Standards: 570,510, &653- Mechanical

Integrity All the Reported & Unreported Near Misses the Oil & Gas Industry has experienced, but because of: Luck Proper PMI, Inspection Training (RAGAGEP ) / API RP 578

Guidelines and Application Procedures for API-RP 578 Positive Material Identification (PMI) Using XRF and OES Technologies

Because of the previously discussed information and my experience with both selling XRF Analyzers and training personnel in the Petrochemical and Refining Oil and Gas business, Analytical Training Consultants, Inc. has produced the API 578 PMI Certification Training Course:

Questions
Don Mears, President
Analytical Training Consultants, Inc. (ATC)
4801 Woodway, Suite 377W Houston, Texas 77056 Cell Phone: 281-684-8881 ATC Office: 713-400-1001 Fax: 713-621-6488 www.API578.com